Ethics and compliance - IN.SI.

To promote ethical principles in business behavior in implementation of the law converting Decree Law 29/2012, the Competition and Market Authority (AGCM), in conjunction with the Ministries of Justice and the Interior, resolved in November 2012 the Regulations to define the attribution of the legality rating to companies operating in the national territory with a turnover above 2 million euros.

The Legality Rating is aimed at the promotion and introduction of principles of ethical behavior in the corporate sphere, through the assignment of a judgment on the respect for legality by companies that have requested it and, more generally, on the degree of attention placed on the proper management of their business.

IN.SI. S.r.l. was assigned a rating of **+ on 18/03/2015 (RT498)

Code of Ethics

The Code of Ethics constitutes a code of conduct, the observance of which by all corporate officers is of fundamental importance to the smooth operation, reliability and Cmpany reputation.

IN.SI. S.r.l. has adopted and issued a Code of Ethics, which makes explicit the values to which all Recipients must conform, accepting responsibilities, roles and rules for the violation of which, even if no corporate liability to third parties follows from it, they assume personal responsibility within and outside the Company.

The knowledge and observance of the Code of Ethics by all those who work with IN.SI. S.r.l. are therefore primary conditions for the transparency and reputation of the Company.

IN.SI. S.r.l. is committed to the diffusion of the Code of Ethics among all those with whom it has business relations, demanding knowledge of it and compliance with the rules contained therein.

Organizational Model

The Board of Directors of IN.SI. S.r.l. on 30/07/2015 adopted, concerning Legislative Decree no. 231/01, the “Organizational Model” aimed at preventing the commission of offenses that may result in the administrative liability of the Company when carried out in the interest/advantage of the Entity itself.

IN.SI. S.r.l. believes that the adoption of this Model, together with the issuance of the Code of Ethics, constitutes, beyond the requirements of the law, a tool so that employees, collaborators, and all other parties with which the Company interacts (Customers, Suppliers, Partners, etc.) follow, in the performance of their activities, correct and transparent behavior in line with the ethical-social values that IN.SI. S.r.l. in the pursuit of its corporate purpose, and such, in any case, as to prevent the risk of commission of the offenses contemplated by the Decree.

The “Organizational Model” of IN.SI. S.r.l. has been prepared in accordance with the Confindustria Guidelines (2014) and consists of the following sections:

  1. Model General Part, which contains an indication of the inspiring principles, identification of the offenses provided for by Legislative Decree 231/01 and the relevant sanctions, description of the company IN.SI. S.r.l., the regulations of the supervisory body, the disciplinary system and elaborates in particular the results of the Risk Assessment phase, the findings of which are reported in the following attachments:
  • Annex 1: Matrices of sensitive processes at risk of crime divided by areas pursuant to Legislative Decree 231/01;
  • Annex 2: Assessment of the potential and residual risk of each crime.
  1. Model Special Part containing the specific procedures to be adopted for risk management in the characteristic areas and the procedures instrumental to the operation of sensitive processes.

Supervisory Body (OdV)

Article 6. letter b) of Legislative Decree 231/2001 requires that the task of supervising the operation of and compliance with the indications of the Model, as well as taking care of its updating, be entrusted to a body within the company with autonomous powers of initiative and control.

In implementation of the provisions of the Decree, the Board of Directors of IN.SI. S.r.l., with a resolution of 07/30/2015, entrusted a Collegial Body with the task of assuming the functions of “Supervisory Body” (SB). The Collegial Body is composed of three members.

The Supervisory Body (OdV) supervises the effectiveness and adequacy of the 231 Model, reports on its implementation, approves the annual program of supervisory activities, and reports on the outcome of activities carried out in the exercise of assigned duties.

In order to ensure maximum effectiveness of action, information flows are provided to the Supervisory Board (OdV) and from it to top management.

To contact the Supervisory Body: